Originally published on lexsummary.com.
NEC Corporation v. Anker Innovations Technology Co., Ltd. et al, No. 2:24-CV-00720-JRG (E.D. Tex. June 4, 2026) (Gilstrap, J.)
Overview
Judge Rodney Gilstrap of the Eastern District of Texas denied Defendants Anker Innovations Technology Co., Ltd. and Anker Innovations Ltd. (d/b/a “eufy”)’s motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). Anker sought to invalidate the asserted claims of four NEC patents as patent-ineligible under 35 U.S.C. § 101 using the Alice framework. The Court denied the motion in all respects, finding that the claims either were not directed to abstract ideas at step one or, alternatively, that NEC raised plausible factual allegations of unconventionality sufficient to survive at step two.
Background
NEC sued Anker for infringing six U.S. patents relating to object detection methods for video and image processing systems, alleging that Anker’s smart doorbell products (sold under the “eufy” brand) infringe these patents. Anker’s motion challenged four of the six patents:
- U.S. Patent No. 9,953,240 (the “‘240 Patent”)
- U.S. Patent No. 10,037,467 (the “‘467 Patent”) — object detection and tracking in moving image data
- U.S. Patent No. 11,210,526 (the “‘526 Patent”) — video processing with region-based categorization for machine learning
- U.S. Patent No. 11,537,814 (the “‘814 Patent”) — data collection and transmission for training machine learning models
After Anker filed its motion, NEC dropped the ‘240 Patent from the case and updated its asserted claims for the remaining three patents.
The Court’s Analysis
‘240 Patent — Moot
Because NEC voluntarily dropped the ‘240 Patent after Anker’s motion was filed, the Court denied as moot the portion of Anker’s motion directed to that patent.
‘467 Patent — Not Directed to an Abstract Idea
Anker argued that the ‘467 Patent claims were directed to the abstract idea of “detecting and tracking features of an object in images and associating information with the features.” The Court disagreed, finding that the claims specify a particular detection, extraction, selection, and association process that improves the functionality of an image processing system, rather than merely invoking computers as a tool for an abstract image processing concept. The Court noted that Anker’s characterization “too broadly characterizes claim 1 and attempts to stretch the precedent,” and that Anker’s analogy to a security guard performing these tasks “oversimplifies the technical solution.” Even assuming arguendo that the claims were directed to an abstract idea, NEC raised plausible factual allegations about the unconventionality of the claimed techniques that preclude resolution at the pleadings stage under Berkheimer.
‘526 Patent — Abstract at Step One, Saved at Step Two
The Court agreed with Anker that the ‘526 Patent claims are directed to the abstract idea of “labeling data to train a machine learning model,” finding this consistent with the Federal Circuit’s recognition in Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205 (Fed. Cir. 2025), that “the very nature of machine learning” includes using “selected training material.” However, at Alice step two, NEC raised plausible factual allegations that specific claim features—including acquiring operator-designated sub-regions, generating new categories, and accumulating learning data—are unconventional, and Anker offered no basis at the pleadings stage to conclude these techniques were well-known, routine, or conventional.
‘814 Patent — Abstract at Step One, Saved at Step Two
Similarly, the Court found the ‘814 Patent claims directed to the abstract idea of “using machine learning to identify objects in data and selecting training data.” But again, NEC’s specific factual allegations regarding the unconventionality of the claimed determination and transmission units—which determine whether data should be sent to a predetermined computer for model training and transmit it at a predetermined timing—were sufficient to survive the pleadings stage. Citing Cellspin Soft, Inc. v. Fitbit, Inc., 927 F.3d 1306 (Fed. Cir. 2019), the Court held that these factual disputes preclude judgment on the pleadings.
Holding
The motion for judgment on the pleadings is DENIED in all respects. The ‘240 Patent portion is denied as moot. The ‘467 Patent claims survive at Alice step one. The ‘526 and ‘814 Patent claims, while directed to abstract ideas at step one, survive at step two because NEC pleaded plausible factual allegations of unconventionality that cannot be resolved on the pleadings.
Key Takeaway
This decision illustrates the continuing vitality of Berkheimer‘s holding that whether claim elements are well-understood, routine, and conventional is a factual question requiring clear and convincing evidence. Even where a court agrees that patent claims are directed to abstract ideas at Alice step one, specific factual allegations of unconventionality in the complaint can defeat a Rule 12(c) motion. The opinion also shows that courts will resist overly broad characterizations of patent claims at step one, particularly where claims recite specific technical processes rather than mere data collection and analysis.